Privacy Policy

Last Modified: October 18, 2023

Prior Privacy Policy available here.

This Privacy Policy, published at, applies to our Service, which includes the content, features, applications, and products we offer on the website, the educational mobile application for iOS and Android " English for Kids" in any available version (the “App”) and our other websites, applications, and services that link to this Privacy Policy, irrespective of the manner you access and/or use them, e.g., whether on a PC or through the tablet/mobile device. Your use of our Service is subject to this Privacy Policy and our Terms of Use published at

Please read this Privacy Policy carefully. If you have any questions about this Privacy Policy or would like to exercise any of your rights in respect to personal data, you may contact us via email specified in section 1 below (AI Buddy contact details).

We may update this Privacy Policy from time to time in order to comply with applicable laws. If we make a material change to this Privacy Policy, we will provide you with appropriate notice either by prominently posting a notice of such changes or by direct notification to you. Your continued use of the Service after the effective date will be subject to the new Privacy Policy.

Please note that this Privacy Policy does not apply to activities of third parties, whom we do not own, control, and/or to whom we do not issue mandatory instructions. If you wish to disclose your information to such third parties, including, in connection with the Service use, please make sure you have read and understood their policies on personal data processing and that you agree with such. We bear no responsibility for the privacy practices of any third party.

1. AI Buddy contact details

“We”, “us” or “AI Buddy” in the Privacy Policy refer to AI BUDDY, INC. For the purposes of the General Data Protection Regulation 2016/679 and any implementing legislation (the "GDPR") AI Buddy shall be deemed as the controller of the data received through the Service.

You may contact us as follows:

  • Via email:
  • By post: 707 Continental Cir, #1132, Mountain View, California, 94040, United States
  • Phone number: +1 (434) 436-2469

2. Children’s Privacy

We value the privacy of children as well as their parents, caregivers, and legal guardians who are in control of the child's data (collectively “Legal Guardians”). We have posted this Privacy Policy to help both children and their Legal Guardians understand how a child's personal information will be treated as that child makes use of the Service.

Since the App may be used by children, we require parental control and permission to Service, used by a child. Only a Legal Guardian may create and manage the account on the Service, install the App, make payments, and provide the child’s information where it may be required as a part of the Service use.

We also apply a Parental Gate, which is a standard measure to protect children from sharing their personal information online. A Parental Gate is a special page or screen with a knowledge-based authentication quiz targeted at adults. By solving an age-appropriate quiz, users of the Service prove that they are adults. The Parental Gate may also ask for a birth date, but only to identify whether a user is an adult or a child, to further confirm that the content beyond the Parental Gate is visible only to adults. Please note that information about age may be stored on our servers in aggregate de-personalized form, and may contribute to the analytical data we use to develop and enhance the Service.

We collect the information on a child as may be reasonably necessary to the child’s use of the Service. We may collect the following information on a child: name, age, gender, language level (English), and voice recordings.

Children under 13 can use the Service without providing contact information. Any areas of the Service which require providing personal information are made available only to adults and protected by a Parental Gate, as further described above.

We collect personal information that adults knowingly provide to us using special forms or emails. Access to any forms by which information may be disclosed to us is restricted by the use of Parental Gates.

When advertising our Service, we do not knowingly target children.

You can manage or remove your child’s personal information by contacting us through the methods provided in this Privacy Policy. We may require some additional information to verify your identity before we provide any information or make corrections.

Should you believe that we collected personal data of children through the Service or that the child posted his data within our website without the relevant Legal Guardian’s consent, please contact us, so that we could promptly delete irrelevant data and take all the necessary steps.

3. Why we collect your information

We may collect and use your data due to the following reasons:

  • due to the contract, to provide you with our products and Service;
  • due to our legitimate interest, which includes account management (e.g. making Service personalized, maintaining Service and effective customer and technical support, processing requests and applications, processing and receiving payments for the Service use, sending you notice on material changes in this Privacy Policy or Terms of Use, sending technical or billing notifications), working with legal claims, analytics, and management reporting (e.g. improving our Service and maintaining the security protection of the data and the Service), understanding of the market where we operate, improving the quality of the Service and development of new products;
  • due to your consent, to send you notifications on Service updates, special offers, pricing information, newsletters, and other information.

4. Information we collect on you

Data personally received from you

  • information you provide us upon creation of the account and/or signing up for the Service: your contact information: email, cell phone number. In addition, we may request your date of birth (your age) for the Parental Gate, however, we do not store the information on your age.
  • information you provide us upon your usage of the Service: first name of your child and his/her age; your child’s gender, comments, reviews, and feedback that you send us;
  • billing information, payment method, and any further details that we may need to process your payments. The billing information that you enter is not stored by us, but instead is retained by our payments processing vendor (i.e. Apple, Google, etc.) for the sole purpose of processing payments made in respect to the Service.
  • data that we receive from you in order to process your requests (including requests on Service support), inquiries, or claims;
  • data that you provide us upon participation in our marketing or promo activities;
  • data that you provide us when participating in various surveys, polls, questionnaires, etc.;
  • data on your use of the Service (e.g., account settings, preferences, etc.);
  • information you make available when posting on our pages in third-party resources (e.g. AppStore, Google Play, our pages in social networks).

Data received automatically

  • information about your device: cookie ID on your browser, User agent (UA), session start/stop time, platform, SDK version, timestamp, UDID (device identifier), technical information about the device (for example, device model and name, operating system name and version, processor information, screen size, firmware, software, mobile operator, Internet service provider, application API key ID, Android ID, Android serial number), push notification token (so that we can determine if you subscribed to push notifications);
  • location data, your language, and territory settings, including language, IP address; country, city, or region data, and time zone. The location information is being collected based on your IP address and is restricted to the name of your country. We are not using other technologies to determine your location (we do not use GPS or other sensors). We do not collect location information about your exact whereabouts (i.e. name of the street or accurate address);
  • information about your connection to the Service (Network status (Wi-Fi, etc.), browser plug-in types and versions;
  • data of the App version that you use;
  • billing parameters of your account (subscription period, date and time of payment, account, and currency of payment, transaction ID, your Service account ID, etc.);
  • information about your use of the Service (your progress, App activities, log files, various features of the Service are used, as well as information about the frequency, number, and length of each use session). This information is used in the aggregate form only and it is not treated as personal information. For instance, we may use this data to develop appropriate educational content for particular age groups;
  • data on your interaction with the website when you are being transferred to our website or an App. 

Data received from other sources (including automatically received)

  • analytical and/or statistical data from third parties (e.g., our marketing/advertising partners, analytics partners, etc.);
  • data on you, which may be contained in a third-party complaint, including public authorities and/or law enforcement bodies;
  • your information that we receive when you register and/or link your account on Services with any third-party service you have (including Google, Apple, social networks, etc.); 
  • card number and issuer, date and time of payment, and other data that the payment system/agent may provide us in order to process your payment;
  • Please note that we may not control which data you specify to us. In case you use the data of any third party, you must obtain consent from such affected third party prior to any disclosure of his/her information to us and/or with the use of the Service. In case you have no explicit consent from third parties for disclosure of their information, please make sure that you are fully compliant with other grounds for such use of the personal data, as required under the applicable laws;
  • By allowing other people to use the Service via your account, you confirm that you have the right to consent on their behalf to collect, use, and disclose their personal information by us as described in this Privacy Policy;
  • We do not carry out any decision-making based solely on automated processing, including profiling.

5. How we collect your information

Directly from you when

  • you create an account on our Service;
  • you specify the information on the Service;
  • you contact us through the Service or otherwise;
  • you subscribe to our emails;
  • you tag us and comment on a third-party service.


When you navigate through the Service and interact therewith, we may receive the information on your device and its software, your use of the Service, errors of the Service, etc.

From third parties

When you link your account within the Service with any social network or third-party services (including Google, Apple, or any other available through the Service). Such third parties will share your information based on their own privacy policies and privacy settings you may choose therein. We recommend you check your settings on such third-party resources before linking the account and modifying the scope of information you want to share with us:

  • when we receive respective information from public authorities, regulators, and/or law enforcement bodies (for example, when we receive an inquiry from them in respect to you);
  • when you make payments through the third-party services, including payment systems;
  • when we receive advertising and/or analytics from our third-party contractors in order to support our marketing activities, improve our Service, identify your location;
  • when we may get certain information on your use of the Service from the cookies and related third-party technologies.

6. How we keep and protect your data

We use a system of appropriate and reasonable technical and organizational security measures to protect the information we collect. Personal information is stored behind security networks and accessible only to a limited number of persons, who are required to keep the information confidential. We use encrypted communications to transfer personal information over the internet. However, please note that regardless of any efforts, no data transmission can be 100% secure and protected. You should only access the Service within a secure environment.

7. How long we keep your data

We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Policy or until we receive your request to erase personal data unless otherwise required or permitted by law (such as tax, accounting, or other legal requirements). 

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

8. Voice collection

The App involves a character that interacts with users via voice. The App captures audio recordings during such interactions. Under COPPA, audio recordings containing children's voices ("Recordings") are considered to be "personal information."

The App involves children talking with a virtual character. Since a child may say anything when interacting with the character, a child may accidentally or inadvertently provide personal information that our character wasn't asking for. For instance, the child may say his name to the character. In this case, it is our policy to delete any transcripts associated with such information immediately upon detection.

Recordings made through the App on the Android system are available through Google Play, Xiaomi Mi GetApps, Samsung Galaxy Store, Huawei AppGallery, and Amazon Appstore

Such Recordings, save for the Exclusions, are sent directly to our servers for speech recognition and transcription purposes and then processed by the Natural Language Processing and Artificial Intelligence technology (proprietary technology developed by AI BUDDY, INC.) to enable the App and provide most of its features with the transcripts of the Recordings. Exclusions: For the following countries the Recordings are processed by your device and sent to us as a transcription: Austria, Belgium, Bulgaria, Croatia, Cyprus, Czechia, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden. For such a list of countries we will not receive and store the Recordings.

Recordings made through the App on the iOS system are available through the Apple App Store

Such Recordings are sent by you to Apple for speech recognition and transcription purposes. We then receive transcripts (without attached audio) of such Recordings from Apple and process them to provide the Service, enable the App, and provide most of its features. Please acknowledge that Apple may use the audio data from these Recordings to improve and provide Apple products and services. In order to improve our Service, we may use transcript processing, processed by the Natural Language Processing and Artificial Intelligence technology developed by AI BUDDY, INC. that enables the App and provides most of its features with the transcripts of the Recordings that we receive from Apple. We do not store or process any Recordings from Apple; however, we do process the transcripts of such Recordings. We do not store any such transcripts locally on user devices. 

All Recordings (as described above in respect to the Android system) and transcripts of the Recordings (for both systems) are stored in aggregated and depersonalized form and are used to improve the efficacy of our App's lessons. No audio recordings or transcripts are in any way associated with users' device IDs, IP addresses, or other identifiers that may be used to identify any users or their personal information. Thus, such information is not treated as personal information under this policy.

9. How we share your data

We will not share personal information we collect through our Service with third parties (including the child’s data), except in the instances described below:

  • With voice recognition service providers such as Apple. Such voice recognition service providers may process the personal information we provide to them on our behalf, in order to test, improve, and further develop our speech recognition and artificial intelligence technologies.
  • For the purpose of operating our business, we may transfer information between us and certain trusted third-party service providers (e.g. processing of purchase orders or marketing campaigns), that act as independent contractors on our behalf, in compliance with this Privacy Policy. We will remain responsible for their handling of your information per our instructions. We provide our service providers only with the information necessary for them to perform their services and we work with them to respect and protect your information. These parties are contractually prohibited from using personally identifiable information for any purpose other than for the purpose we specify.
  • When you give us your consent to do so, or if we notify you that in connection with the Service the information that you provide will be shared.
  • As an act of good faith, we may disclose specific information in response to a court order, when required by law, to enforce our Service policies, or to protect our or others' rights, property, or safety and in other cases as provided under COPPA or other applicable laws.
  • We may transfer the personal information of our adult users in situations where personal information may be disclosed or transferred as one of our business assets. For example, in connection with (or during negotiations of) any merger, acquisition, financing, or sale of a company's assets.

We do not allow advertising companies to gather data through our Service.

10. Rights you have

You have a relevant scope of rights in respect to your information as provided by applicable law. In general, you are entitled to obtain information from us on how we handle your personal data, to review or change the information in your account or terminate your account, and to see copies of all personal data held by us. 

If you are located in the European Economic Area or United Kingdom, you may also have the right to limit, restrict, or object to the processing of your personal information. If you are from the specified countries and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority in certain circumstances.

To access, correct, or delete your personal information please email us at We will delete your personal information immediately upon your request, but please note that this will not affect the lawfulness of the processing before its withdrawal, nor when applicable law allows will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent. Cached copies may exist for a certain period of time even after your information is deleted.

Since our policy is not to keep children's personal information, such data will always be immediately deleted upon detection. 

You can unsubscribe from our marketing and promotional communications at any time by contacting us as specified in this Privacy Policy. You will then be removed from the marketing lists. However, we may still communicate with you, for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

11. Cookies and Tracking Policy

In order to improve the quality of our products and Service, we use cookies, tracking technologies, and other technologies such as pixel tags, web beacons, and clear GIFs to collect non-personal data to improve the Service. It helps us to track the statistics of user interaction with our products and Services, and identify and resolve technical problems. 

We collect information through Amplitude, Appsflyer, Facebook, Airbridge, Google Analytics, and Segment services. User Data is transmitted to and stored on such third-party servers. Details of the personal data processing policy can be found on the Internet at:

Emails we send you may contain code that enables us to track the usage of this communication, including whether it was opened and acted upon.

You may manage your cookies preferences via your browser and/or device settings. The majority of Internet browsers will enable you to delete cookies from your computer’s hard drive, refuse acceptance of cookies and/or receive a specific warning before cookies are stored within your system.